Table of Contents
- What is ALARA?
- What is a Radiation Protection Program?
- What are the requirements of a Radiation Protection Program?
- Why am I not notified prior to an inspection?
- Why can't the inspector come back to my facility to re-inspect the items that were out of compliance during the inspection?
- What documentation should I include with my response to a Notice of Violation?
- I do not agree with a violation I received. What should I do?
- I gave the inspector my new address. Why wasn't the address changed on my license?
- Why was I cited for a violation even though I sent a request to change my license?
- I haven't changed the way I do things in years, but was cited for a violation that I was never cited for before. Why?
- I spoke with someone in the Austin office and was told I did not need to follow certain sections of the regulations even though they were listed on my license. What should I do?
- I want to change a form I use. Does the revised form need to be approved by the Agency before I use it?
- Do I have to leak test the sealed sources that are not in use and in storage?
- Why do I need to reference background radiation on radiation surveys?
- What is required to discontinue the use of personnel monitoring?
- Why am I responsible for the actions of my employees?
- Why am I required to keep transfer records for radioactive material I no longer possess?
- Why am I required to provide financial assurance?
1. What is ALARA?
As low as is reasonably achievable (ALARA) means making every reasonable effort to maintain exposures to radiation as far below the dose limits set in the regulations as practical. Exposure to ionizing radiation shall be as low as reasonably achievable considering the benefits derived from its use and the consequences incurred from any exposure.
2. What is a Radiation Protection Program?
Each licensee shall develop, document and implement a Radiation Protection Program (RPP) to ensure they meet the requirements of Title 25 Texas Administrative Code Chapter ยง289.202, "Standards for Protection Against Radiation from Radioactive Material." The extent of the program depends on the magnitude of the licensee's operations and may be incorporated into your operating, safety and emergency procedures. The effort to be ALARA is no longer recommended, it is required. Each licensee shall do everything reasonable to maintain doses to workers and the public ALARA. A licensee is not required to be ALARA, but is bound to employ every reasonable practice and control to strive for ALARA.
3. What are the requirements of a Radiation Protection Program?
In addition to what is described in the previous question, your RPP must be reviewed at intervals not to exceed 12 months for content and proper implementation. The licensee is required to maintain records of the RPP. The records shall include the provisions of the program and audits and other reviews of program content and implementation. The records will be reviewed during an Agency inspection.
4. Why am I not notified prior to an inspection?
The general policy of the Agency and a requirement of the State's agreement with the United States Nuclear Regulatory Commission is to perform unannounced inspections. You may be contacted by an inspector to schedule an inspection if there are time and travel constraints or it is a more efficient use of resources to make advance accommodations.
5. Why can't the inspector come back to my facility to re-inspect the items that were out of compliance during the inspection?
Once an inspection has been conducted, the information collected is submitted in a report to the central office in Austin, were the report is reviewed for completeness and accuracy. Once the report is reviewed a formal notification of the compliance findings will be sent to you for your response. Return visits to inspection sites are not possible because of limited travel funds and staff, therefore you are requested to respond to violations in writing. The inspector will verify compliance during the next inspection.
6. What documentation should I include with my response to a Notice of Violation?
Read the guide included with the Notice of Violation on how to respond and what to submit. Your response should include a statement that you currently have documentation of compliance. The documentation will be verified during the next inspection.
7. I do not agree with a violation I received. What should I do?
You do have the right to dispute violations. Your response to the violation must include specific reasons and/or documentation pertaining to your dispute. General disagreement with regulation content is not sufficient cause for a dispute. You are afforded a 24 hour time period following an inspection to supply documents to the inspector that were not available at the time of the inspection.
8. I gave the inspector my new address. Why wasn't the address changed on my license?
To have the address or any other part of your license changed, you must submit a request in writing informing us of the change. You should state if the change is only the mailing address or if it is a new radioactive material storage location. If the change involves a new storage location, you are required to submit site specific information, add the site to your license and receive an amended license prior to storing radioactive material there.
9. Why was I cited for a violation even though I sent a request to change my license?
Unfortunately, the timing of a request can result in noncompliance. You can't implement changes you have requested until your license has been amended authorizing the change.
10. I haven't changed the way I do things in years, but was cited for a violation that I was never cited for before. Why?
During the inspection process, an effort is made to review all aspects of the licensed activity. Because a violation was not identified previously, does not invalidate it as an item of noncompliance.
11. I spoke with someone in the Austin office and was told I did not need to follow certain sections of the regulations even though they were listed on my license. What should I do?
Always comply with the provisions of the regulations listed on your license and your procedures unless specifically authorized or exempted, in writing, to do otherwise.
12. I want to change a form I use. Does the revised form need to be approved by the Agency before I use it?
No. As long as the form contains the information required by the regulations or your operating, safety and emergency procedures.
13. Do I have to leak test the sealed sources that are not in use and in storage?
No. However, you are required to document that the sources are in storage. If you transfer or use a source from storage, you must have the results of a leak test that was performed within the previous 6 months.
14. Why do I need to reference background radiation on radiation surveys?
Background radiation is natural in origin and all humans receive exposure to ionizing radiation as an inevitable part of living in today's world. The background reading is the reference reading, or start point from which to make accurate radiation surveys.
15. What is required to discontinue the use of personnel monitoring?
The licensee must document that users of radioactive material will not receive more than 10% of the allowable annual occupational dose, which is 5 rem. Your documentation should include evidence to support your determination, such as work load, time and distance calculations. If any of the conditions used to support your determination change, you should reevaluate the need to provide personnel monitoring.
16. Why am I responsible for the actions of my employees?
The licensed entity is ultimately responsible for the problems that arise from the operations under their license. It is the licensed entity's responsibility to provide adequate training and employee oversight to assure compliance with regulatory requirements.
17. Why am I required to keep transfer records for radioactive material I no longer possess?
Transfer records are your proof that you transferred the source of radiation to an authorized recipient. Should a radioactive source become lost or stolen, the transfer record will document that you disposed of the source properly.
18. Why am I required to provide financial assurance?
The regulations require that licensees provide documentation of financial assurance that guarantees the availability of funds for decommissioning of their facilities. The amount of financial assurance required is dependent on the form and amount of radioactive material authorized, not possessed, by the specific license.